A Virginia appellate court upheld an anti-spam conviction in the face of first amendment questions. The Virginia Computer Crimes Act prohibits sending bulk email through a “computer network with the intent to falsify or forge electronic mail transmission information or other routing information.” The defendant argued the statute violated his first amendment right to anonymous speech. The court decided the statute’s prohibition on “trespassing on private computer networks through intentional misrepresentation” reaches only that amount of speech necessary to further the state’s legitimate public interest in controlling high volumes of junk email.